-
Aviation Advisory
Our dedicated Aviation Advisory team bring best-in-class expertise across modelling, lease management, financial accounting and transaction execution as well as technical services completed by certified engineers.
-
Consulting
Our Consulting team guarantees quick turnarounds, lower partner-to-staff ratio than most and superior results delivered on a range of services.
-
Business Risk Services
Our Business Risk Services team deliver practical and pragmatic solutions that support clients in growing and protecting the inherent value of their businesses.
-
Deal Advisory
Our experienced Deal Advisory team has provided a range of transaction, valuation, deal advisory and restructuring services to clients for the past two decades.
-
Forensic Accounting
Our Forensic and Investigation Services team have targeted solutions to solve difficult challenges - making the difference between finding the truth or being left in the dark.
-
Financial Accounting and Advisory
Our FAAS team designs and implements creative solutions for organisations expanding into new markets or undertaking functional financial transformations.
-
Restructuring
Grant Thornton is Ireland’s leading provider of insolvency and corporate recovery solutions.
-
Risk Advisory
Our Risk Advisory team delivers innovative solutions and strategic insights for the Financial Services sector, addressing disruptive forces, regulatory changes, and emerging trends to enhance risk management and foster competitive advantage.
-
Sustainability Advisory
Our Sustainability Advisory team works with clients to accelerate their sustainability journey through innovative and pragmatic solutions.
-
Corporate Accounting and Outsourcing
At Grant Thornton we have extensive knowledge and experience in providing tailored solutions to our clients, whether on a short-term or long-term basis.
-
Financial Services Audit
Our Financial Services Audit team offers expertise and knowledge along with a horizontal approach to solving clients’ problems and queries.
-
Global Statutory Audit
Our Global Statutory Audit team ensures your statutory audit process follows a well-defined project plan, with no surprises, to maintain compliance across multiple jurisdictions. We invest time to understand your finance function and develop bespoke solutions built on the premise of central effort to remove duplication.
-
Pension Audit
The Grant Thornton Pension Audit team has vast experience in managing schemes and preparing annual reports on them for clients.
-
Corporate Tax
Our Corporate Tax team is made up of more than 40 highly experienced senior partners and directors who work directly with a wide range of domestic and international clients; covering Corporation Tax, Company Secretarial, Employer Solutions, Global Mobility and Tax Incentives.
-
Financial Services Tax
The Grant Thornton team is made up of experts who are fully up to date in terms of changing and evolving tax legislation. This is combined with industry expertise and an in-depth knowledge of the evolving financial services regulatory landscape.
-
Indirect Tax Advisory & Compliance
Grant Thornton’s team of indirect tax specialists helps a range of clients across a variety of sectors including pharmaceuticals, financial services, construction and property and food to navigate these complexities.
-
International Tax
We develop close relationships with clients in order to gain a deep understanding of their businesses to ensure they make the right operational decisions. The wrong decision on how a company sells into a new market or establishes a new subsidiary can have major tax implications.
-
Private Client
Grant Thornton’s Private Client Services team can advise you on all areas of financial, pension, investment, succession and inheritance planning. We understand that each individual’s circumstances are different to the next and we tailor our services to suit your specific needs.
Receive the latest insights, news and more direct to your inbox.
In this bulletin, the CBI has provided its observations on a number of significant and widespread deficiencies across authorisation applications received from VASPs where roughly 90% of all applications are not meeting the required standard.
The result of these deficiencies is that the CBI is not satisfied that firms will be able to effectively manage and mitigate the Money Laundering (‘ML’) and Terrorist Financing (‘TF’) risks they face. VASPs brought within the scope of Anti Money Laundering and Countering the Financing of Terrorism (AML / CFT) Supervision following the updating of the Criminal Justice (Money Laundering and Terrorism Financing) Act in April 2021, and as such are required to meet the obligations set out therein. Important to note that VASPs are supervised by the CBI for AML/CFT purposes only - so this bulletin carries even more significance.
Key observations on applications
Incomplete applications
A number of authorisation applications were incomplete as they did not contain the required information and documentation (e.g. submitting a copy of the internal risk register in place of a documented risk assessment or submitting policies with no related procedures). These applications were not progressed to the assessment stage.
Applications which progressed to the assessment stage also displayed a number of recurring issues.
Risk Assessment
Firms should underpin their AML/CFT framework with a ML / TF Business Risk Assessment which documents the specific ML/TF risks posed by their products, customers and activities.
The CBI found that a number of firms did not appropriately assess ML / TF risks, at both an inherent and residual level, related to their customers and / or business activities. Firms also did not consider risk factors as set out in the Irish national risk assessment or CBI AML/CFT Guidelines for the Financial Sector.
Policies and Procedures
A firm’s AML / CFT framework should include a detailed suite of policies and procedures. These policies and procedures should reflect operational practices and align with all legal and regulatory requirements.
CDD
Firms should understand the risks posed by their customers, and should collect appropriate documentation to identify and verify the identity of customers, along with any beneficial owners. Firms should understand the customer’s intended purpose for the account or service, and the expected activity. Firms are also required to identify customers that are Politically Exposed Persons (‘PEPs’) as part of the CDD process to ensure they fully understand the risks arising from the customer relationship.
Financial Sanctions Screening
The CBI expects that firms implement an effective screening system to identify sanctioned parties. This system should be supported by clear escalation procedures should a firm identify a positive match.
Several applicant firms failed to document how they would conduct customer screening (i.e. what tool or reg-tech solution would be implemented). A number of firms also failed to document the frequency of customer screening, along with how and what steps would be taken in the event of a positive sanctions match.
Outsourcing
Whilst firms may outsource certain AML/CFT functions, they remain ultimately responsible for ensuring compliance with their legal obligations. Any outsourced activities should be supported by a documented agreement of obligations on the outsourced service provider, with details of how oversight will be maintained by the firm throughout the course of the agreement.
While a number of applicant VASP firms outsource certain AML / CFT functions, the CBI found that the applications did not include outsourcing policies, procedures, or service level agreements. Firms also failed to demonstrate oversight or assurance testing of outsourced activities.
Presence and Pre-Approval of Controlled Function role holders
It is the CBI’s expectation that a firm has at least one employee in a senior management role located in Ireland to act as point of contact with the CBI. Failure to appropriately meet this requirement may lead to the refusal of an application.
In addition, a number of firms also failed to submit Individual Questionnaires for the proposed Pre-Approval Controlled Function (PCF) role holders in a timely manner.
How can we help?
Grant Thornton understands the challenges faced by VASPs in meeting the CBI and regulatory expectations with respect to AML / CFT. We are well positioned to support firms in addressing these challenges, with a team over 75 + financial crime specialists with deep regulatory and industry experience.